OSHA Form 300: How to Record Pre-existing Injuries

Posted on 6/5/2012 by James Griffin

Q. If I have an employee who has a pre-existing injury from something non-work-related, but she becomes reinjured while doing her job, do I have to record the injury?
A. The Occupational Safety and Health Administration (OSHA) requires employers to record each fatality, injury, and illness that is:
  1. A new case, and
  2. Work-related, and
  3. Meets one or more of the general recording criteria at 29 CFR 1904.7
[29 CFR 1904.4]
Defining Different Types of “Work-Related” Injuries
Today, we’ll focus on the second trigger: the injury must be “work-related.” In most cases, this is fairly straightforward, but it may become confusing when an injury that occurs at work is a result of a pre-existing condition that occurred outside of work.
Let’s do an example. Let’s say that John injures his shoulder playing softball with his friends on Saturday. He comes into work on Monday and begins his work shift and is initially able to do his job. After he’s been working for a couple hours, however, he wrenches his shoulder lifting some heavy boxes and has to take off work for the next week to recover. Would John’s injury be considered work-related if his shoulder was known to be previously injured from a non-work-related incident?
In this case, yes, it would need to be recorded. If a pre-existing injury or illness is “significantly aggravated” by an exposure in the work environment, then that aggravation makes the recurrence of the injury or illness a new case of a work-related injury/illness.
Pre-Existing Conditions Can Be “Significantly Aggravated”
A pre-existing injury has been “significantly aggravated” when an event or exposure leads to one of the following:

  • One or more days away from work, days of restricted work, or days of job transfer,
  • Medical treatment or a change in medical treatment,
  • Loss of consciousness, or
  • Death.
[29 CFR 1904.5(b)(3)-(4)]
In John’s case, his pre-existing shoulder injury alone wouldn’t have required him to take time off work. However, when he lifted the boxes for his job, that activity aggravated his injury to the point where he had to take time off from work, making his injury work-related and creating an incident that must be recorded on the OSHA 300 log.
Avoid Recordable Injuries with Better Communication
Let’s do another example, this time of an incident that will not be recorded. On Sunday, Jane hurts her knee skiing. Before work begins on Monday, she informs her supervisor of the injury and is reassigned to do paperwork instead of physical activity for a few days.
A day of restricted work or job transfer as the result of an injury is usually recordable. However, as this reassignment occurred before any occupational exposures could aggravate Jane’s condition, her injury is solely the result of outside factors and, therefore, her case is not work-related and does not need to be recorded on the OSHA 300 log.
What difficulties have you found in determining a work-related injuries? Do you have any advice or tips for filling out the OSHA 300 log?

Tags: osha, reporting and recordkeeping

Find a Post

Compliance Archives

Lion - Quotes

Attending Lion Technology classes should be mandatory for every facility that ships or stores hazmat.

Genell Drake

Outbound Lead

The instructor did an excellent job presenting a very dry subject; keeping everyone interested and making it enjoyable.

Marc Bugg

Hazardous Waste Professional

We have a very busy work schedule and using Lion enables us to take the course at our own time. It makes it easy for me to schedule my employees' training.

Timothy Mertes

Hazmat Shipping Professional

The instructor made the class enjoyable. He presented in a very knowledgeable, personable manner. Best class I've ever attended. Will take one again.

John Nekoloff

Environmental Compliance Manager

Lion's course was superior to others I have taken in the past. Very clear in the presentation and the examples helped to explain the content presented.

George Bersik

Hazardous Waste Professional

The instructor was probably the best I ever had! He made the class enjoyable, was humorous at times, and very knowledgeable.

Mary Sue Michon

Environmental Administrator

My experience with Lion training, both online and in the classroom, is that they are far better organized and provide a better sequential explanation of the material.

Robert Roose

Manager, Dangerous Goods Transportation

This training broke down the regulations in an easy-to-understand manner and made them less overwhelming. I now feel I have the knowledge to make more informed decisions.

Amanda Oswald

Shipping Professional

Excellent class, super instructor, very easy to follow. No rushing through material. Would like to take his class again.

Lawrence Patterson

EH&S Facility Maintenance & Security Manager

The workshop covered a lot of information without being too overwhelming. Lion is much better, more comprehensive than other training providers.

George Alva

Manufacturing Manager

Download Our Latest Whitepaper

Ace hazmat inspections. Protect personnel. Defend against civil and criminal penalties. How? See the self-audit "best practices" for hazardous materials shippers.

Latest Whitepaper

By submitting your phone number, you agree to receive recurring marketing and training text messages. Consent to receive text messages is not required for any purchases. Text STOP at any time to cancel. Message and data rates may apply. View our Terms & Conditions and Privacy Policy.